Each
semester, CARU hosts an intern. This summer semester, Jessica A, a law student,
joined the CARU staff. Here is some insight into a day in the life of a CARU
intern, written by our intern herself.
My
first assignment as an intern at CARU was to evaluate a certain mobile app that
is directed at children for compliance with COPPA and CARU’s self-regulatory
program (the Guidelines). I was
instructed by one of the staff attorneys to begin by reading the app’s privacy
policy to learn about its data collection practices. After the app successfully
downloaded and I was excited to get started, I was bombarded by in-app
advertisements. Then, gameplay led me to realize that while the app was free to
download, the “catch” was that the free version offered limited features. There
existed heavy sales pressure to unlock additional features via pop-ups for in-app
purchases. As I sat tapping away on the phone’s touchscreen, I received curious
glances from NAD staff members who might easily have assumed I was
unprofessionally texting or tweeting on the job!
The
above describes one of many exciting responsibilities of a CARU intern. Interns
and staff attorneys alike monitor apps, websites, television commercials, print
ads, and other advertisements for compliance with CARU’s Guidelines as well as federal laws such as COPPA. CARU aims to help
advertisers and website operators bring their designs into compliance before they subject themselves to fines
imposed by the FTC but more importantly, before
children’s inherent vulnerabilities can be exploited.
Throughout
the summer, I have learned that the CARU staff engages in routine monitoring
and much more. The CARU staff also runs the first FTC-approved COPPA safe
harbor program, records and archives case reports, pioneers research on issues
related to children’s media, and presents conferences that bring together the
key players in the industry. For example, in anticipation of the July 1st
date of the FTC’s COPPA Rule Amendments coming into effect, CARU brought
together its Supporters to discuss the Amendments (including the Amendments’
effect on the future of online behavioral advertising). As an intern, it was
exciting to be in the same room with general counsels and representatives of
major children’s television networks and toy companies as well as leading
privacy and advertising lawyers and other great minds. The '90s child within me
wanted to run up to some of these people and blurt out how much I loved growing
up with their programming and products! I also wanted to tell them how I still
sometimes watch “kid’s TV” and peruse toy stores when I feel nostalgic (hey,
don’t pass judgment, I am sure you sometimes linger on the kid’s networks when
flipping through channels!).
In
sum, CARU is awesome and it has been a pleasure to intern here! I have learned
about industry self-regulation and children’s media law whilst conducting legal
research and writing. With the FTC’s COPPA Rule Amendments newly in effect, the
office’s excited air is contagious. The staff is busy guiding and advising
their safe harbor participants as well as engaging in routine monitoring. My
summer internship has provided me with an invaluable experience. I leave here
with a different outlook on commercials, websites and apps geared towards
children. I now can’t help asking myself - is that character wearing a helmet
while riding that bike? Is that family eating excessive amounts of food
contrary to normal portion sizes? Is that product being advertised labeled
‘Keep out of reach of children’? Does this website need to obtain verifiable
parental consent?
I
thank the entire CARU staff for the amazing opportunity to join them this
summer and look forward to seeing more of the amazing work that CARU does.